Revised conditions for Brazilian GMO soybeans have reportedly removed key safeguards against viable seeds, invasive super weeds and plant pathogens (viruses, bacteria, fungi), raising serious questions about verification inspections, treatment and enforcementm
ISLAMABAD: Pakistan’s decision to relax biosecurity import conditions for importing genetically modified (GMO)/ living modified organism containing viable soybeans from Brazil and USA has raised serious concerns about the possible entry of invasive super weeds, crop diseases nematodes mites and other pests into the country’s agricultural system besides serious environmental risks as the revised import conditions reportedly remove several essential safeguards previously required to prevent entry of biosecurity risk and GMO/LMO contamination to environment. These conditions are also violating article 15, 16 and 18 of Cartagena Protocol that deals transboundary movement of GMO/LMOs.
The revised import conditions, issued on August 1, 2026 by National Agri Trade and Food Safety Authority (NAFSA) administration have reportedly waived mandatory seed devitalisation in violation of EPA license, relaxed requirements for additional declarations certifying consignments free of specified quarantine pests and super weeds, and placed greater reliance on phosphine fumigation, a treatment primarily used to control stored grain insects except Khapra beetle and low respirating stages of insects to whom it become resistant n has no control.
The changes have also raised serious questions about the adequacy of cargo inspections, the monitoring of shipments during transportation and the authority responsible for enforcing Pakistan’s plant quarantine regulations and biosafety regime.
According to former Director General, department of plant protecrion, (DPP), Dr Tasneem Ahmed, Brazilian soybean imports carry potential risks from 116 quarantine pests, including 42 insects, 27 weeds, 25 fungi, eight bacteria, six viruses, six mites and two nematodes.
These organisms can threaten crops, spread plant diseases and introduce invasive weed species into agricultural areas. The concerns are particularly significant for Pakistan, where agriculture supports millions of livelihoods and provides raw material for major industries, including textiles.
Under the previous import conditions introduced from 2018 onwards, Brazilian soybean consignments were required to undergo measures to ensure that seeds could not germinate even during accident or spillage unintentional release so that they cannot persist in local environment. These included verified additional declarations from the exporting country’s plant protection authority and approved treatments, such as dry-heat treatment gamma irradiation, ethylene oxide or methyl bromide fumigation, supported by germination testing.
According to plant protection expert namely Mr Faisal Shehzad former Entomologist DPP, revised conditions have reportedly removed or weakened several of these requirements.
Risk of viable seeds entering agricultural areas
One of the principal concerns relates to the removal of the requirement that imported GMO soybeans have zero germination capacity.
Rule 49 of the Pakistan Plant Quarantine Rules, 2019, requires GMO soybeans imported for industrial crushing or processing to be rendered incapable of germination.
The purpose is to ensure that imported grain does not become a source of unauthorised cultivation or accidental spread and persist in local environment.
Previously, International Seed Testing Association (ISTA) certificates were used to verify that imported seeds had no germination capacity. The Pakistan Environmental Protection Agency also imposes conditions under the Pakistan Biosafety Rules, 2005, including requirements relating to seed devitalisation and verification of approved GMO events.
The removal of these safeguards could allow viable seeds to enter the country and potentially germinate if spilled during transportation or handling or in any accident and for which there is no emergency measures devised both by NAFSA and Pak EPA.
The risk does not end at ports. Imported soybeans are transported from Karachi to processing facilities, including destinations hundreds of kilometres away in Punjab. If viable seeds escape from trucks or cargo during transit, they could reach agricultural land.
The revised conditions reportedly require transportation under sealed conditions but do not specify detailed arrangements such as leak-proof containers, designated routes, GPS tracking, biosecurity monitoring or procedures for dealing with accidental spills.
Removal of safeguards against 27 invasive weeds
Another major concern is the removal of the mandatory additional declaration relating to quarantine weed seeds under Schedule V of the Pakistan Plant Quarantine Rules, 2019.
According to the cited pest-risk assessment, Brazilian soybean imports may carry 27 invasive weed species that are not currently established in Pakistan.
The additional declaration is important because it requires the exporting country’s plant protection authority to certify that specified prohibited pests or weeds are absent from the consignment.
Without this certification, quarantine inspectors may face greater difficulty identifying and intercepting prohibited weed seeds mixed with bulk soybean shipments.
The revised conditions instead place significant reliance on aluminium phosphide, which releases phosphine gas and is primarily used as an insect fumigant.
However, phosphine does not destroy weed seeds or render soybean seeds incapable of germination. It therefore cannot replace seed devitalisation or certification measures designed to prevent the introduction of invasive plants.
The technical objections raises by quarantine experts namely Mr Omer musab, former entomologist DPP, also question the composition and legal status of a committee reportedly consulted during the revision of the import conditions. The committee included officials from the Punjab Agriculture Department, a University of Agriculture Faisalabad PBG professor and a chemist from the HEJ Research Institute of Chemistry.
Questions have been raised about whether the committee had the specialised plant quarantine expertise required to assess the risks associated with the import of agricultural commodities.
Questions over the effectiveness of fumigation
According to biosecurity expert, Mr. Ejaz Rao, the revised conditions also designate phosphine fumigation as the principal pre-shipment treatment, but the technical objections point to a lack of clearly defined treatment parameters.
Effective fumigation depends on several factors, including dose, gas concentration at different intervals, temperature and exposure time. These must be specified and monitored to establish whether a treatment can eliminate the targeted pests.
According to the objections, the revised permit does not prescribe sufficiently clear minimum treatment parameters and instead refers importers exporters and NPPO Brazil to product labels in Brazil.
The objections further state that the Brazilian phosphine product label specifies a total treatment cycle of 17 days, comprising 10 days of exposure, three days of ventilation and four days of withholding.
It identifies a limited range of storage pests, including grain weevils, red flour beetles and cigarette beetles, among others.
However, the technical objections raised by Mr Azaz Ahmad former Entomologist DPP allege that a Brazilian soybean vessel was permitted to undergo fumigation for only one day with phosphine raising questions about compliance with the applicable product label and the effectiveness of the treatment even against prescribed by FAO.
More importantly, phosphine is not a comprehensive treatment against the full range of biological threats identified in the pest-risk assessment. It cannot be relied upon to eliminate fungal spores, bacterial diseases, plant viruses, mites and nematodes, while dormant insect eggs and pupae may also require specific treatment conditions.
The objections therefore argue that relying primarily on phosphine without additional inspection, testing and treatment measures leaves several categories of biological risks unaddressed.
Weak controls at the source of exports
The revised conditions have also raised concerns about the absence of requirements for sourcing soybeans from officially recognised pest-free areas or places of production when you at least withdrawal appropriate treatment to mitigate associated pests.
International plant protection standards, including ISPM Nos. 4 and 10, provide guidance on establishing and recognising pest-free areas and places of production.
Such controls are intended to reduce the risk of contaminated agricultural commodities entering international trade at their source.
The concerns are particularly relevant because a technical audit conducted by former directors technical of DPP under instruction from MNFSR in Brazil in 2021 reportedly identified weaknesses in port quarantine inspections, elevator inspection, pest control program at soybean fields, fumigation facilities and the availability of accredited laboratories needed to meet Pakistan’s phytosanitary requirements.
The findings, as described in the objections, suggested a need for stronger monitoring and inspection arrangements. However, the subsequent relaxation of import conditions has raised questions about whether the identified shortcomings were adequately addressed.
Unclear contamination standards and limited inspections
The revised permit also requires imported cargoes to arrive clean and substantially free from soil, plant debris and animal contamination.
However, the relevant condition reportedly does not specify measurable contamination limits, sampling procedures or laboratory testing methods.
This is significant because soil and plant debris can carry harmful organisms, including fungal spores, bacterial pathogens and nematodes.
Without clearly defined standards and scientifically valid sampling procedures, inspectors may find it difficult to determine whether a consignment meets the required biosecurity standards.
The revised inspection arrangements have also been criticised for relying heavily on visual examination.
Visual inspection can identify visible contamination and some pests, but it cannot reliably detect microscopic fungal spores, latent plant viruses, internal insect larvae or weed seeds mixed with bulk grain.
International plant protection standards provide for more comprehensive inspection and sampling approaches, including the systems approach under ISPM 14, which combines multiple measures to manage phytosanitary risks.
According to a former entomologist of DPP the revised conditions do not provide sufficiently detailed sampling and laboratory-testing arrangements to identify foreign seed admixtures or verify the presence of specific GMO events and unauthorized GMOs.
He also points to the reported removal of clear enforcement procedures under Rule 46 of the 2019 Rules, which provides for measures such as treatment, re-export or destruction of non-compliant consignments.
Instead, the revised arrangements are alleged to leave greater discretion to the Director General of the Department of Plant Protection.
Questions over regulatory authority
Dr Tasneem Ahmed further raised objections that the changes have also raised questions about the administrative process through which the new conditions were introduced.
According to the objections, the revised conditions were issued on August 1, 2026, by Yasin Murtaza, an Additional Collector of Customs serving as Director General of the Department of Plant Protection under the National Agri Trade and Food Safety Authority (NAFSA).
The objections question whether the appointment and technical qualifications of the official concerned meet the requirements of an institution responsible for Pakistan’s National Plant Protection Organisation (NPPO).
They also challenge a provision in the revised permit allowing import conditions to be amended through mutual agreement between the importing and exporting plant protection organisations.
The concern is that such a provision could weaken Pakistan’s independent authority to determine the phytosanitary conditions under which agricultural commodities are allowed to enter the country.
Article VII of the International Plant Protection Convention (IPPC) recognises the authority of contracting parties to regulate imports for plant health protection, subject to their international obligations.
The permit has also reportedly contained an internal inconsistency, with one section describing the cargo’s GMO status as “Nil” while adjacent sections identify specific genetically modified events.
This has raised further questions about the accuracy and completeness of the documentation governing the imports.
Lessons from previous agricultural losses
Pakistan has previously experienced the economic consequences of plant diseases and invasive pests.
Cotton Leaf Curl Virus severely affected the country’s cotton sector during the 1990s, while the subsequent spread of pests such as Fall Armyworm, invasive thrips, mealybugs and Parthenium weed has created additional challenges for farmers.
These experiences underline the importance of preventive measures at ports of entry because controlling an invasive pest after it becomes established can be considerably more difficult and expensive than preventing its introduction.
The central issue is therefore not whether Pakistan should facilitate soybean imports or commercial trade. It is whether trade facilitation can be pursued without compromising the country’s plant health safeguards.
The objections to the revised conditions call for a technical review of the August 1 decision, restoration of scientifically justified seed-devitalisation and pest-certification requirements, clearly defined fumigation standards, stronger laboratory testing and effective monitoring of cargo during transportation.
Once an invasive pest, disease or weed becomes established in agricultural land, its eradication may be extremely difficult, if not impossible.
For a country whose economy and food security depend heavily on agriculture, maintaining effective plant quarantine controls is therefore an essential part of protecting national agricultural resources.
Courtesy Profit
